Privacy Policy

Action Canada for Sexual Health and Rights is a Canadian non-profit and charity registered with the Canada Revenue Agency.

Our mailing address is:
501-240 Bank Street
Ottawa, ON K2P 1X4

Email: info@actioncanadashr.org

Telephone: 613-241-4474

This Privacy Policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.

Under the various laws, you have the following rights, which we will work to uphold:

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
• The right to access the personal data we hold about you. Part 10 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

We may collect some or all of the following personal data (this may vary according to your relationship with us):

• Name
• Address
• Email address
• Telephone number
• Business or organization name
• Job title
• Profession
• Payment information
• Information about your preferences and interests
• For Access Fund clients, information related to the support we provide you through our Access Fund

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

• Providing and managing your account.
• Supplying our products or services to you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email or postal mail that you have opted-in to. You may unsubscribe or opt-out at any time by updating your communication preferences at secure.actioncanada.org.
• With your permission and/or where permitted by law, we may also use your personal data for marketing or fundraising purposes, which may include contacting you by email with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations, and you will always have the opportunity to opt-out.

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

• Donation financial data will pass through this site and be stored by our payment processors until complete, and in our fundraising database;
• Event participation information will be stored on secure.actioncanadashr.org (our CRM) until the event has ended, with a record of which events you participated in added to your record if applicable;
• Newsletter subscriptions (by interest, geography or site collected) will be stored on secure.actioncanadashr.org until you unsubscribe;
• Access Fund client information will be stored on a separate secure site for as long as needed for data purposes.

We will only store data provided through our websites in Canada. We occasionally export mailing information to a mailing house that will not store any personal data after use.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may sometimes contract with the following third parties to supply products or services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

• Credit card payment processors 
• Beyond the Basics order fulfilment
• Third party marketing contracted by Action Canada for a specific campaign.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

Contact information (including mobile phone data) will not be shared or sold to third parties for marketing purposes.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal address shown in Part 11. 

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request on within 10 business days of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: privacy@actioncanadashr.org

Telephone number: 613-241-4474 x 10800

Postal Address: Privacy Officer, Action Canada for Sexual Health and Rights, 501-240 Bank Street, Ottawa, ON K2P 1X4.